Privacy Policy

1. Introduction

Paulivai B.V. ("we," "us," or "our"), a company registered in the Netherlands with its office at Huub van Den Brulestraat 62, 3065 PG Rotterdam, Netherlands, is committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit our website, use our services, or interact with us in any way. This policy applies to all individuals who access our website or engage with our coaching and personal development education programs.

We process personal data in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679, the Dutch Implementation Act of the GDPR (Uitvoeringswet Algemene verordening gegevensbescherming – UAVG), and other applicable data protection legislation in the Netherlands.

2. Data Controller

The data controller responsible for your personal data is:

3. Personal Data We Collect

We may collect and process the following categories of personal data:

3.1 Information You Provide Directly

• Identity Data: Full name, title, or preferred name.
• Contact Data: Email address, phone number, and mailing address.
• Program Data: Program preferences, enrollment information, and educational interests.
• Communication Data: Messages, inquiries, feedback, or other correspondence you send to us through our contact form or email.
• Consent Data: Records of your consent to receive communications or for data processing purposes.

3.2 Information Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device type, and screen resolution.
• Usage Data: Pages visited, time spent on pages, navigation paths, referral sources, and clickstream data.
• Cookie Data: Information collected through cookies and similar technologies as described in our Cookie Policy.

3.3 Information from Third Parties

We may receive personal data from third-party analytics providers, advertising platforms, or referral partners. This data is used solely for the purposes described in this policy and is processed in compliance with applicable data protection laws.

4. Legal Basis for Processing

Under the GDPR, we process your personal data based on one or more of the following legal grounds:

• Consent (Article 6(1)(a) GDPR): Where you have given us explicit consent to process your personal data for specific purposes, such as sending you information about our programs or processing a contact form submission.
• Contract Performance (Article 6(1)(b) GDPR): Where processing is necessary to perform a contract with you or to take steps at your request prior to entering into a contract, such as enrolling you in a coaching program.
• Legitimate Interests (Article 6(1)(f) GDPR): Where processing is necessary for our legitimate interests, provided that such interests are not overridden by your fundamental rights and freedoms. Our legitimate interests include improving our website, understanding user behavior, and preventing fraud.
• Legal Obligation (Article 6(1)(c) GDPR): Where processing is necessary to comply with a legal obligation to which we are subject under Dutch or EU law.

5. How We Use Your Personal Data

We use the personal data we collect for the following purposes:

• To respond to your inquiries and provide information about our coaching and personal development programs.
• To process program registrations and manage your participation in educational programs.
• To communicate with you regarding your enrollment, program updates, or changes to our services.
• To improve our website, services, and educational content based on usage patterns and feedback.
• To ensure the security and proper functioning of our website.
• To comply with applicable legal requirements and regulatory obligations under Dutch law.
• To send you educational updates and program information, where you have consented to receive such communications.
• To analyze website usage and optimize user experience.

6. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data to third parties. We may share your personal data in the following limited circumstances:

• Service Providers: We may share data with trusted third-party service providers who assist us in operating our website, conducting business activities, or servicing you, provided they agree to keep your information confidential. These may include hosting providers, email service providers, and analytics tools.
• Legal Requirements: We may disclose your personal data if required to do so by Dutch law or in response to valid requests by public authorities (e.g., a court or regulatory body in the Netherlands).
• Business Transfers: In the event of a merger, acquisition, or asset sale involving Paulivai B.V., your personal data may be transferred as part of that transaction. We will provide notice before your personal data becomes subject to a different privacy policy.
• Protection of Rights: We may disclose your data when we believe disclosure is necessary to protect our rights, your safety, or the safety of others, or to investigate potential policy violations.

7. International Data Transfers

As Paulivai B.V. is based in the Netherlands and serves participants in Canada, personal data may be transferred to and processed in countries outside the European Economic Area (EEA). Where such transfers occur, we ensure that appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission.
• Adequacy decisions issued by the European Commission for certain countries.
• Other legally recognized transfer mechanisms under the GDPR.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements under Dutch law.

• Contact Form Data: Retained for up to 24 months after your last interaction with us, unless you request earlier deletion.
• Program Enrollment Data: Retained for the duration of your participation plus a period of up to 36 months for administrative and legal purposes.
• Technical and Usage Data: Retained for up to 12 months.
• Financial Records: Retained for up to 7 years as required by Dutch tax and accounting regulations (Belastingdienst requirements).

When personal data is no longer required, it is securely deleted or anonymized.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted through our website.
• Secure server infrastructure with firewall protection.
• Access controls limiting data access to authorized personnel only.
• Regular security assessments and updates.
• Secure data storage practices compliant with industry standards.

While we take all reasonable steps to protect your personal data, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security but are committed to continuously improving our safeguards.

10. Your Rights Under GDPR

Under the GDPR and the Dutch UAVG, you have the following rights regarding your personal data:

• Right of Access (Article 15 GDPR): You have the right to request a copy of the personal data we hold about you.
• Right to Rectification (Article 16 GDPR): You have the right to request correction of inaccurate or incomplete personal data.
• Right to Erasure (Article 17 GDPR): You have the right to request deletion of your personal data, subject to certain legal exceptions.
• Right to Restriction of Processing (Article 18 GDPR): You have the right to request that we restrict the processing of your personal data under certain circumstances.
• Right to Data Portability (Article 20 GDPR): You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object (Article 21 GDPR): You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent (Article 7(3) GDPR): Where processing is based on consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days, as required by the GDPR.

11. Right to Lodge a Complaint

If you believe that our processing of your personal data violates your rights under the GDPR, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

12. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and analyze website usage. For detailed information about the cookies we use, their purposes, and how to manage your cookie preferences, please refer to our Cookie Policy.

13. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to read the privacy policies of any third-party sites you visit.

14. Children's Privacy

Our services and educational programs are intended for adults (individuals aged 18 and older). We do not knowingly collect personal data from children under the age of 16. If we become aware that we have inadvertently collected personal data from a child under 16, we will take steps to delete that information promptly.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory obligations. When we make material changes, we will update the "Last updated" date at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

16. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Netherlands, including the GDPR and the Dutch Implementation Act (UAVG). Any disputes arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Rotterdam, the Netherlands.

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us: